(1.) Although this appeal was admitted on 22.1.2000, no substantial question of law was framed at the time of admission.
(2.) After hearing Learned Counsel for the parties, we frame the following substantial question of law:
(3.) A search and seizure operation was conducted under Section 132(1) of the Income-Tax Act, 1961 ('the Act') in the residential premises of the assessee on 3.1.1996. The assessee is the Managing Director of two private limited companies whose business premises were also covered by the search operations.